Our Privacy Policy

Keys to Living

Please take a moment to review our privacy policy and practices below.

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NOTICE OF PRIVACY PRACTICES

This Notice of Privacy Practices includes the following locations:

1642 42nd Street NE, Cedar Rapids, IA 52402 – Phone 319-377-2161 – Fax: 319-377-2094

1700 S 1st Ave, Suite 22, Iowa City, IA 52240

Your Information.

Your Rights and Choices

Our Responsibilities.

This notice describes how information about you may be used and disclosed and how you can get access to this information. Please review it carefully.

Your Rights

When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.

Obtain an electronic or paper copy of your medical record

• You can ask to see or get an electronic or paper copy of your medical record and other health information we have about you. Ask us how to do this.
• We will provide a copy or a summary of your health information, usually within 15 days of your request. We may charge a reasonable, cost-based fee.

Ask us to correct your medical record

• You can ask us to correct health information about you that you think is incorrect or incomplete. Ask us how to do this.
• We may say “no” to your request, but we’ll tell you why in writing within 60 days.

Request confidential communication

• You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address.
• We will say “yes” to all reasonable requests.

Ask us to limit what we use or share

• You can ask us not to use or share certain health information for treatment, payment, or our operations. We are not required to agree to your request, and we may say “no” if it would affect your care.
• If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information for the purpose of payment or our operations with your health insurer. We will say “yes” unless a law requires us to share that information.

Receive a list of those with whom we’ve shared information

• You can ask for a list (accounting) of the times we’ve shared your health information for six years prior to the date you ask, who we shared it with, and why.
• We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.

Get a copy of this privacy notice

• You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.

Choose someone to act for you

If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information.

• We will make sure the person has this authority and can act for you before we take any action.

Final Things

Social Networking Sites: Due to the restrictions of confidentiality and your therapist’s code of ethics, he/she will not be able to respond to, or even acknowledge, any requests for communication via various social networking sites such as but not limited to “Facebook”, “LinkedIn” etc.

Changes to the Terms of this Notice

We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our office and on our website.

Complaints: File a complaint if you feel your rights are violated

• If you are concerned that one of us has violated your privacy rights, or you disagree with a decision made about access to your records, you may contact Tim Hunter, our Executive Director at (319)377-2161.
• You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/.
• We will not respond negatively to you in any way for filing a complaint.

Your Choices

For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions.

In these cases, you have both the right and choice to tell us:

• To share information with your family, close friends, or others involved in your care
• To share information in a disaster relief situation

If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.

Our Uses and Disclosures

While HIPAA allows for certain sharing your personal health information, Iowa law is more stringent regarding its disclosure. Keys to Living Counseling Center adheres to Iowa Code Chapter 228 Disclosure of Mental Health and Psychological Information.

We typically use or share your health information without your consent for the following purposes:

Treating you.

Your therapist may share information about your case in collaborating with another Keys to Living therapist to better assist you. Your identifying information typically is not disclosed. Example: Your therapist may discuss options for your treatment with colleague to best design your therapy.

Managing our organization.

We can use and share your health information to run our practice, improve your care, and contact you when necessary. Example: We use health information about you to manage your treatment and services.

Billing for your services.

We can use and share your health information to bill and get payment from health plans or other entities. Example: We give information about you to your health insurance plan so it will pay for your services.

Collecting past due fees provided that a client has been given the opportunity to arrange for payment first and there has been no timely response. Example: We can share limited information with a collections service to collect past due fees.

Comply with the law. We will share information about you if state or federal laws require it:

• If the Department of Health and Human Services wants to determine that we’re complying with federal privacy law.
• Address workers’ compensation, law enforcement, and other government requests
• For law enforcement purposes or with a law enforcement official
• With health oversight agencies for activities authorized by law
• For special government functions such as military, national security, and presidential protective services

Comply with mandated reporting laws.

• Reporting suspected abuse or neglect of a minor child or a dependent adult.
• Preventing/reducing a serious threat to anyone’s health or safety.
• Preventing or reducing a serious threat to your health or safety

For research, audit, or program evaluation purposes, provided that patient-identifying information is not redisclosed.

Respond to lawsuits and legal actions

We can share health information about you in response to a court or administrative order. We can only share information in response to a subpoena if you agree in writing for us to do so. We can only share information about you if other adult participants in therapy also sign a release to do so.

• To comply with a court order or with an involuntary commitment proceeding
• To a specified family member involved in providing care for the patient if the disclosure is necessary to provide care for the patient.

Our Responsibilities

• We are required by law to maintain the privacy and security of your protected health information.
• We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
• We must follow the duties and privacy practices described in this notice and give you a copy of it.
• We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.

We never market or sell personal information. We will not contact you for fundraising efforts.

For more information see: https://www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html

https://www.legis.iowa.gov/docs/ico/chapter/228.pdf

This Notice was adapted from U.S. Department of Health and Human Services and the Iowa Code Chapter 228.

Reproductive Health Information:

We may not disclose your reproductive health information to a party requesting the information if that party’s purpose is to:

• Conduct a criminal, civil, or administrative investigation for the mere act of seeking, obtaining, providing, or facilitating reproductive health care.
• Impose criminal, civil, or administrative liability, for the mere act of seeking, obtaining, providing, or facilitating reproductive health care, or
• To identify any person involved in the acts described above.

For example, we will not disclose your reproductive health care information to law enforcement whose purpose is to investigate a patient’s lawful receipt of reproductive health care in another state.

Should we receive a request for PHI related to reproductive healthcare, we will obtain a signed attestation from the requesting party that the information is not being sought for a purpose prohibited by the HIPAA Privacy Rules.

APPENDIX A

Notice of Privacy Practices of Keys to Living Part 2 Program

This notice describes:

• HOW HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED
• YOUR RIGHTS WITH RESPECT TO YOUR HEALTH INFORMATION
• HOW TO FILE A COMPLAINT CONCERNING A VIOLATION OF THE PRIVACY OR SECURITY OF YOUR HEALTH INFORMATION, OR OF YOUR RIGHTS CONCERNING YOUR INFORMATION

YOU HAVE A RIGHT TO A COPY OF THIS NOTICE (IN PAPER OR ELECTRONIC FORM) AND TO DISCUSS IT WITH TIMOTHY HUNTER, EXECUTIVE DIRECTOR AT 319-377-2161, TIM@KEYSTOLIVING.ORG IF YOU HAVE ANY QUESTIONS.

OUR USES AND DISCLOSURES OF YOUR HEALTH INFORMATION

The following is a summary of the limited circumstances under which we may acknowledge your presence or disclose information about you to individuals outside of Keys to Living without your permission.

Medical Emergencies. We may disclose your information to medical personnel to the extent necessary to meet a bona fide medical emergency during which you are unable to provide prior informed consent of the disclosure.

Research. Under certain circumstances, we may disclose your information for scientific research, subject to certain safeguards.

Audit and Evaluations. We may disclose information to others for specific audits or evaluations, including those who conduct audits and evaluations necessary by state or federal agencies.

Reporting Certain Criminal Conduct. The following information is not protected by Part 2:

• Information related to your commission of a crime on the premises of a Keys to Living facility.
• Information related to your commission of a crime against Keys to Living personnel; and
• Reports of suspected child abuse and neglect made under state law to the appropriate state or local authorities.

Individuals Involved in Your Care. Depending on your age and mental capacity and the location of your services, we may be permitted to make certain disclosures of your information to your guardian, for payment purposes, and your guardian may be permitted to consent to disclosures of your information.

Judicial Proceedings. We may disclose information about you in response to a court order and subpoena that comply with the requirements of the regulations.

YOUR RIGHTS

Ask us to limit what we use or share.

• You may request to restrict or limit disclosures made with prior authorization for purposes of treatment, payment, or our health care operations.
• If you have paid for the item or service in full, you may ask us to restrict the disclose of that health information with your health plan.

Request an accounting of disclosures we have made to share your information.

• You can request a list (accounting) of disclosures where we have shared your health information, to include who we shared it with, and why, for the past three (3) years.
• This includes the right to a list of disclosures by an intermediary for the past three (3) years.

Receive a copy of this notice.

• You may ask us to give you a copy of this notice at any time. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice. Contact us using the information set forth above to promptly receive a copy of this notice.
• You may also obtain a copy of this notice at our website: www.KeysToLiving.org

We will never share your information unless you give us written permission.

• To elect not to receive fundraising communications.
• A single authorization (consent) may be provided for all future uses or disclosures for treatment, payment, or health care operations purposes.

OUR RESPONSIBILITIES

• We will not use or share your information other than as described in this notice unless you tell us we can in writing.
• If you give us permission to share information, you may change your mind at any time. Let us know in writing if you change your mind. This will stop any further use or disclosure of your information for the purposes covered by your written authorization.
• We are required by law to maintain the privacy of records, to provide patients with notice of our legal duties and privacy practices with respect to records, and to notify affected patients following a breach of unsecured records.
• We are required to abide by the terms of this notice currently in effect.

CHANGES IN THE TERMS OF THIS NOTICE

We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for information we already have about you as well as any information we receive in the future. The new notice will be available on request, on our website and in our facility. The updated notice will contain the effective date with the revisions.

VIOLATIONS OF LAWS AND REGULATIONS

A violation of the federal law and regulations governing the confidentiality of substance use disorder records is a crime. Suspected violations may be reported to the Substance Abuse and Mental Health Services Administration Center for Substance Abuse Treatment at 5600 Fishers Lane Rockville, MD 20857 or (240) 276-1660 or to the US Attorney for the district in which the violation occurred.

(Revised 10-15-2024)